Use of representatives: Uncompensated representatives

This section contains policy, procedures and guidance used by IRCC staff. It is posted on the department’s website as a courtesy to stakeholders.

Family, friends, non-governmental and religious organizations

Individuals who provide citizenship or immigration advice and who do not charge a fee or receive any form of compensation, whether directly or indirectly, for their services do not need to be members of a recognized regulatory body to act as a representative or provide advice/guidance.

Family, friends, international organizations [e.g., United Nations High Commissioner for Refugees, religious organizations and Non-government Organizations (NGOs)] play an important role for applicants who need support and advice. Family, friends, religious, and other NGOs who do not charge fees or receive consideration for providing citizenship or immigration advice or services can advise and represent applicants before Immigration, Refugees and Citizenship Canada (IRCC) or the Canada Border Services Agency (CBSA) without being members of the Immigration Consultants of Canada Regulatory Council (ICCRC), a Canadian provincial/territorial law society or the Chambre des notaires du Québec at any stage of an application.

International and other organizations

Certain international organizations, such as the International Organization for Migration (IOM), provide a variety of services to clients. If the organization is providing services in accordance with an agreement or arrangement with the Government of Canada (see Entities under agreement with the Government of Canada), or if no consideration is being provided for the provision of immigration or citizenship advice or representation, then they are not in contravention of A91 (1) of Immigration and Refugee Protection Act (IRPA) and subsection 21.1(1) of the Citizenship Act.

Pro bono work

IRCC and the CBSA should not discourage pro bono work by authorized representatives (including students-at-law under a lawyer’s supervision). Pro bono activity by lawyers, notaries and ICCRC members is often encouraged by their governing bodies.

If representatives who are providing pro bono services are members of a Canadian provincial/territorial law society, the Chambre des notaires du Québec or the ICCRC, their respective governing bodies continue to be responsible for their conduct despite the fact that they are not receiving consideration for their services.

However, IRCC officers should be mindful of unauthorized representatives who identify themselves as uncompensated on the Use of a Representative (IMM 5476) form and who submit a significant number of applications as pro bono.

Note: If an officer has concerns about submissions from unauthorized representatives and whether or not they are truly pro bono submissions, they should refer to Handling complaints about unauthorized representatives for details on investigation procedures.

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